Rev. Rul. 2004-104 — 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in … IRCRevenue RulingsNov 15, 2004
EMPLOYEE PLANS
Rev. Rul. 2004-104 Rev. Rul. 2004-104
2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in determining contributions to defined benefit plans and permitted disparity.
Notice 2004-72 Notice 2004-72
20…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
INCOME TAX
Notice 2006-76 Notice 2006-76
This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
IRCCourt RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsMar 9, 2011related by meaning
…the Taxpayer (for example, as a taxable dividend
if the Business is a C corporation). * * * [Notice 2004-8,
2004-1 C.B. at 333; emphasis added.]
Thus, Notice 2004-8, supra, clearly assumes that an income tax
adjustment will be made no matter which of the three avenues of
attack the Service chooses.
Service notices do n…
T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified… IRCTreasury DecisionsApr 17, 2006related by meaning
SPECIAL ANNOUNCEMENT
Announcement 2006-22 Announcement 2006-22
This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
IRCCourt RulingsJun 13, 2012
Petitioners elected under section 1377(a)(2) to divide the management
company's 2004 taxable year into two taxable periods--from January 1 to July 12, 2004, and from July 13 to December 31, 2004. During the January 1 to July 12,
2004, taxable period, the ESOP was the sole shareholder of the management
company. During t…
IRCPrivate Letter RulingsApr 2, 1999related by meaning
…d us t o consider whether the rationale of the TAM controls the outcome of
your case. Your incoming memorandum notes that in the present context, unlike in the
TAM, we have information on how the grace period contribution was recorded in the books
and records: i t was booked when paid, consistent with T's method of rec…
IRCCourt RulingsJun 9, 2009
…hen th
e
taxpayer acquires it .l s
Although petitioner testified he acquired
various asset s
during 2004, he also testified that the software assets he
acquired were still under development until approximately
September 2004 when aj,revision of the integrated software wa
s
completed . According, to petitioner, the Viet…
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
he Service anticipate issuing and requests comments on the issues intended to be addressed by such guidance.
Announcement 2007-68 Announcement 2007-68 This document contains numerous corrections to the preamble of final regulations (T.D. 9321, 2007-19 I.R.B. 1123) setting forth guidance on the application of section 40…
IRCCourt RulingsJun 25, 2012related by meaning
…me to verify, adequate substantiation for the matters in question. See Nguyen
v. Commissioner, T.C. Memo. 2003-313 (and cases cited therein). Factual determinations were required to decide whether the distributions from NADA
were taxable, whether the 10% additional tax applied, and whether petitioner was
- 10 -
entitle…
IRCCourt RulingsJun 14, 2012
…her WFR and Yolo would issue
dividends to their shareholders.
II. Yolo's Medical Plan
On January 2, 2004, Mrs. Repetto in her capacity as president of Yolo
established a medical and dental care expense reimbursement plan (Yolo medical
plan) effective January 1, 2004. According to the Yolo medical plan,. Yolo would
reim…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsJun 21, 2011related by meaning
efore the loan was not a
taxable distribution in 2003. On March 21, 2006, the Air Force
removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21,
2006. As a result, the TSP notified petitioner that the loan
provisions required repayment of the outsta…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005
…medial amendment period begins on February 1st following issuance of the Cumulative List. In Notice 2004-84, 2004-2 C.B. 1030, the Service published the 2004 Cumulative List of Changes in Plan Qualification Requirements (2004 Cumulative List). The 2004 Cumulative List was used primarily by plan sponsors and practitione…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
Ann. 2004-52 — Correction; section 457; Rev. Rul. 2004-57. A transition rule is set forth for a plan established before June 14, 2004, that does not satisfy the requirements … IRCAnnouncementsJun 14, 2004
Announcement 2004-52
Correction Under Rev. Rul. 2004-57
Rev. Rul. 2004-57, page this Bulletin, provides that an eligible governmental plan under § 457(b) of the Internal Revenue Code must be established and maintained by an eligible employer as defined under § 457(e)(1)(A). A plan established before June 14, 2004, that…